Comment from Physicians for Social Responsibility

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 Re: Pipeline Safety: Safety of Gas Distribution Pipelines and Other Pipeline Safety Initiatives, Docket Number: PHMSA–2021–0046 To whom it may concern: I am writing on behalf of Physicians for Social Responsibility (PSR) to express our support for strengthening Docket No. PHMSA–2021–0046 regarding the safety of gas distribution pipelines and other pipeline safety initiatives. PSR is an organization that aims to protect human life from the gravest threats to health and survival, making this proposal critically important to our Environment and Health program. The events of the 2018 gas explosions and fires in Merrimack Valley could have been avoided if proper pipeline safety measures had been in place. This incident led to the evacuation of between 15,000 and 50,000 people, loss of gas connectivity to nearly 10,000 homes for several harsh winter months, 25 injuries, and one death. While PHMSA’s proposal aims to protect communities where pipelines are present, there are a number of ways that it could and should be strengthened to avert another disaster. PSR is a proponent of widespread building electrification and the use of renewable energy. The use of gas in homes is dangerous for a number of health and safety reasons. There is, of course, the danger of fires and explosions, but using gas indoors can also cause new cases of childhood asthma and aggravate existing ones as well as impede cognitive development. However, this does not change the fact that many homes across the country are still reliant on gas, so we must prioritize the safety of its transport. As safer pipeline protocols are enacted, there will be fewer large-scale leaks of greenhouse gases, leading to positive short- and long-term benefits. Not only will the risk of injury and deaths from fires and explosions decrease; as leakage decreases, we will see fewer negative health outcomes for local residents and those who work on pipelines. Methane is a potent greenhouse gas; when it is kept out of the atmosphere, it can’t contribute to climate change, which has multiple health and safety impacts, from natural disaster-related injury and death to heat strokes. PHMSA’s proposal contributes to environmental justice via its adherence to Justice40. This is likely to promote equity because it will protect people in low-income communities and communities of color, who are more likely to live in close proximity to pipelines and are more at risk of negative health outcomes from leaks and explosions. PHMSA’s proposal could be improved through strengthening its plan for updated emergency response. Emergency response plans must be updated for relevant pipelines nationwide to increase the emphasis on keeping people nearby safe. In drafting these plans, it is crucial to involve multiple parties, including but not limited to: pipeline operators, first responders, relevant government actors from the local to federal agency level, and local hospital systems. These are the people that need to be prepared for any incident along a pipeline, so their input and knowledge is critical. In this process, operators must take on the bulk of the responsibility for improved record keeping, realistic risk management, and regular maintenance of pipelines. This process should be redundant in order to identify any issues before a small mistake creates an unsafe situation. This redundancy and focus on safety will protect the health of local community members and increase precautions and protections for pipeline workers. Thank you for the opportunity to comment on the agency’s proposal for further pipeline safety measures. This proposal can save lives and should be treated as such. PSR would like to see PHMSA finalize this rulemaking in such a way that public health, occupational safety, and environmental justice are at the forefront. This should be done as soon as possible to avoid another disaster where policy has been lacking, such as the more recent gas explosion in Middleton, ID just last month that required an evacuation order for 10,000 residents. Sincerely, Miah Hornyak, MA Policy Coordinator, Environment & Health Physicians for Social Responsibility